Earlier this month, Apple filed a complaint with a California judge claiming that Samsung was intentionally destroying documents relevant to their ongoing legal spat. Apparently Samsung only handed over a small number of documents that they were ordered to provide, and Apple claims that deleting e-mails is standard practice for Samsung even when they're in the middle of a lawsuit.

Samsung’s ad hoc, unmonitored email “preservation” methods have resulted in the irretrievable loss of unknown volumes of relevant emails. For example, Judge Grewal recently compelled the deposition of Won Pyo Hong, the head of Samsung’s Product Strategy Team, in part due to an email in which Dr.Hong “directly orders side-by-side comparisons of Apple and Samsung products for design presentations."
Apple and the Court cannot possibly know how many more emails Dr. Hong sent or received that would have supported Apple’s claims that Samsung copied Apple products had they not been deleted. The same is true for the many other Samsung witnesses who produced only a handful of emails, or none at all.

Samsung is due to issue a response by May 15, while the complaint is due to be addressed in courts on June 7, though Samsung wants both of those dates pushed back. Apple has previously lodged similar complaints with the ITC, so really, Samsung should already be in a position to address these concerns, but Samsung claims that there's a completely different set of patents and policies in place for for the district of California.

At this point, the patience of judges may be wearing thin; not too long ago, courts asked Samsung and Apple to pare down the number of patent complaints they were leveling at one another. If Samsung is blatantly acting in bad faith, it could easily color the outcome of patent litigation to follow.